HomeMy WebLinkAbout20142435.tiff STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk,MD,MSPH
Executive Director and Chief Medical Officer
yo
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr.S. Laboratory Services Division �tsve s�
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6926 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
www.colorado.gov/cdphe and Environment
Weld County-Clerk to the Board
1150 O St
PO Box 758
Greeley,CO 80632 RECEIVED
August 7,2014 AUG 1 2 201§
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On August 11, 2014,the Air Pollution Control Division will publish a public notice for Noble Energy, Inc—
415850704, in the The Greeley Tribune. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public
copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet
must be available for public inspection for a period of thirty(30)days from the date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health& Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
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%_ t% - 204 2014-2435
STATE OF COLORADO
John W.Hickenlooper,Governor
Larry Wolk,MD,MSPH
Executive Director and Chief Medical Officer eN<rcitt
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr.S. Laboratory Services Division `r t876
Denver,Colorado 80246-1530 8100 Lowry Blvd.Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090
of Public Health
www.colorado.gov/cdphe and Environment
Website Title: Noble Energy, Inc—415850704—Weld County
Released To: The Greeley Tribune
On: August 7,2014
Published: August 11, 2014
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado
Air Pollution Control Division for the following source of air pollution:
Applicant: Noble Energy, Inc
Facility: 415850704
wellpad
SWSW S W Section 17 T8N R61 W
Weld County
The proposed project or activity is as follows: The applicant proposes a new wellpad with 5-300 bbl crude oil
storage tanks with gas flaring.
The Division has determined that this permitting action is subject to public comment per Colorado Regulation No.
3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No.3,Part B, Section III.C.1.a
(25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application,the Division's analysis,and a draft of Construction Permit 13WE2613 have been filed
with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the
Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability of
the proposed project or activity to comply with the applicable standards and regulations of the Commission. The
Division will receive and consider written public comments for thirty calendar days after the date of this Notice.
Any such comment must be submitted in writing to the following addressee:
Rebecca Vasil
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South,APCD-SS-B I
Denver,Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
of
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��'
AIR POLLUTION CONTROL DIVISION #; `
�TELEPHONE: (303)692-3150 ‘9a,,,yj;
1.'979'
CONSTRUCTION PERMIT
PERMIT NO: 1 3WE261 3
Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Batter#415850704, located in the SWSW of Section 17,
Township 8N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Crude Oil Five (5) above ground 300 bbl atmospheric crude oil storage
Storage 003 tanks. Emissions from these tanks are controlled by an enclosed
Tanks flare.
FL- 004 Separator controlled by a flare. Flare has a minimum combustion
415850704 efficiency of 95%. The flare is enclosed.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division(the Division)no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/other-air-permittinq-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control Commission
(AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the
permit.
2. Within one hundred and eighty days(180)after issuance of this permit,compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions.Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, III.G.2).
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Air Pollution Control Division
3. This permit shall expire if the owner or operator of the source for which this permit was
issued:(i)does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit;(ii)discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, IIl.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. Point 004: The following information for all permitted equipment except fugitive emissions
from equipment leaks shall be provided to the Division within fifteen(15)days after issuance
of permit.
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year Equipment ID Point NO Emission Type
CO ype
Crude Oil 003 -- 0.66 --- Point
Storage Tanks
FL-415850704 004 7.8 83.9 42.1 Point
See "Notes to Permit Holder#4"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
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at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Crude Oil
Storage 003 Enclosed Flare VOC, HAPs
Tanks
FL- 004 Separator controlled by a flare stack VOC, HAPs
415850704
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
Crude Oil 003 Crude oil throughput 75,000 BBL/yr
Storage Tanks
FL-415850704 004 Natural gas flaring 150 MMSCF/yr
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months'data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
11. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.)
12. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
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13. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
14. Point 003: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions(State only enforceable). If a flare or other combustion device is used to
control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed, have no visible emissions during normal operations, and be designed so that an
observer can, by means of visual observation from the outside of the enclosed flare or
combustion device, or by other convenient means approved by the Division, determine
whether it is operating properly.The operator shall comply with all applicable requirements
of Section XVII.
15. Point 003: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions(State only enforceable).These requirements include,but are not limited
to:
XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile
organic compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion
device, or by other convenient means approved by the Division,determine whether it
is operating properly.The operator shall comply with all applicable requirements of
Section XVII.
XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with
an operational auto-igniter by or before May 1, 2016, or after the next combustion
device planned shutdown, whichever comes first.
16. Point 003: The storage tanks covered by this permit are subject to Regulation 7, Section
XVII.C emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month
total must operate air pollution control equipment that achieves an average
hydrocarbon control efficiency of 95%. If a combustion device is used,it must have a
design destruction efficiency of at least 98% for hydrocarbons.
XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by
May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio,
visual,olfactory("AVO")and additional visual inspections of the storage tank and any
associated equipment (e.g. separator, air pollution control equipment, or other
pressure reducing equipment)at the same frequency as liquids are loaded out from
the storage tank. These inspections are not required more frequently than every
seven(7)days but must be conducted at least every thirty one(31)days.Monitoring
is not required for storage tanks or associated equipment that are unsafe,difficult,or
inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual
inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
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XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to
ensure that it is operating, including that the pilot light is lit on combustion
devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that
the valves for the piping from the storage tank to the air pollution control
equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the equipment
must be immediately shut-in to investigate the potential cause for smoke and
perform repairs, as necessary, or EPA Method 22 must be conducted to
determine whether visible emissions are present for a period of at least one
(1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to
monitor, the owner or operator is not required to monitor such equipment until it
becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with
air pollution control equipment as required by Sections XII.D. or XVII.C.1.
XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to
air pollution control equipment, and must operate without venting hydrocarbon
emissions from the thief hatch (or other access point to the tank) or pressure relief
device during normal operation, unless venting is reasonably required for
maintenance, gauging, or safety of personnel and equipment. Compliance must be
achieved in accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a
documented Storage Tank Emission Management System("STEM") plan to identify,
evaluate, and employ appropriate control technologies, monitoring practices,
operational practices,and/or other strategies designed to meet the requirements set
forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as
necessary to achieve or maintain compliance. Owners or operators are not required
to develop and implement STEM for storage tanks containing only stabilized liquids.
The minimum elements of STEM are listed below.
XVII.C.2.b.(i) STEM must include selected control technologies, monitoring
practices, operational practices, and/or other strategies; procedures for
evaluating ongoing storage tank emission capture performance; and
monitoring in accordance with approved instrument monitoring methods
following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection
Frequency in Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved
instrument monitoring method in accordance with the following schedule:
XVII.C.2.b.(ii)(b)A storage tank constructed before May 1, 2014, must comply with
the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015.
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Approved instrument monitoring method inspections must begin within ninety
(90)days of the Phase-In Schedule in Table 1, or within thirty (30) days for
storage tanks with uncontrolled actual VOC emissions greater than 50 tons
per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the Inspection
Frequency in Table 1.
Table 1 —Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
> 6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe,difficult,or inaccessible to monitor,as
defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the
selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C.
must maintain records of STEM, if applicable, including the plan, any updates, and
the certification, and make them available to the Division upon request. In addition,
for a period of two (2) years, the owner or operator must maintain records of any
required monitoring and make them available to the Division upon request,including:
XVII.C.3.a. The AIRS ID for the storage tank.
XVII.C.3.b.The date and duration of any period where the thief hatch, pressure relief device,
or other access point are found to be venting hydrocarbon emissions, except for
venting that is reasonably required for maintenance,gauging,or safety of personnel
and equipment.
XVII.C.3.c.The date and duration of any period where the air pollution control equipment is
not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
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XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring such
equipment.
OPERATING & MAINTENANCE REQUIREMENTS
17. Points 003 and 004: Upon startup of these points, the applicant shall follow the operating
and maintenance(O&M) plan and record keeping format approved by the Division, in order
to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to your O&M plan are subject to Division approval prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. Point 004: The operator shall complete an initial site specific extended gas analysis of the
natural gas produced at this site in order to verify the VOC, benzene,toluene,ethylbenzene,
xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission
stream used in the permit application. Results of testing shall be used to determine site-
specific emission factors using Division approved methods. Results of site-specific sampling
and analysis shall be submitted to the Division as part of the self-certification and used to
demonstrate compliance with the emissions factors chosen for this emissions point.
19. Point 004: The owner or operator shall demonstrate compliance with Condition 12 using
EPA Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section
II.A.5).
Periodic Testing Requirements
20. Point 004: On an annual basis, the operator shall complete a site specific extended gas
analysis of the natural gas produced at this site that is routed to the flare in order to verify the
VOC content(weight fraction)of this emission stream used in the permit application. Results
of testing shall be used to determine site-specific emission factors using Division approved
methods.
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5)tons per year,whichever is less, above
the level reported on the last APEN submitted to the Division.
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b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed,or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
22. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold
until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted,then the remainder
of this condition is not applicable. Otherwise,the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the applicant,or the Division revokes a permit,the applicant
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or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Rebecca Vasil
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Noble Energy, Inc.
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Environment
DPolAeF!I' utucHeaFtt1 :nd Air Pollution Control oivision
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No.3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the permittee providing there is no exceedance of any specific emission control regulation or any ambient
air quality standard. A revised air pollution emission notice (APEN) and application form must be
submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
• as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
htto://www.colorado.gov/cs/Satellite?c=Document C&childpanename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paaename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 A 195 No 9.75
003
n-Hexane 110543 C 1425 Yes 71.25
Benzene 71432 A 14020 Yes 701
Toluene 108883 C 5904 Yes 295
004 Ethylbenzene 100414 C 1160 Yes 58
Xylenes 1130207 C 1265 Yes 63
n-Hexane 110543 C 23089 Yes 1154
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
VOC 0.35 lb/bbl 0.0175 lb/bbl Engineering
Calculation
Benzene 0.0026 lb/bbl 0.00013 lb/bbl Engineering
71432 Calculation
n-hexane 0.019 lb/bbl 0.00095 lb/bbl Engineering
110543 Calculation
AIRS ID: 123/9BC3 Page 10 of 12
ik
sr ol•AJ, De =:, en if Public Health and Environment
Air Pollution Control Division
Note: The controlled emissions factors for point 003 are based on the combustor control efficiency
of 95%.These emission factors were developed using a pressurized liquids analysis from the
Sievers LE17-62HN well.
Point 004:
Weight Emission Emission
CAS# Pollutant Fraction of Factors Factors Source
Gas(%) Uncontrolled Controlled
NOx ___ 0.068 0.068 AP-42
lb/MMBtu lb/MMBtu
CO 0.37 AP-42
0.37 lb/MMBtu Ib/MMBtu
VOC 25 22400 1120 Engineering
lb/mmscf lb/mmscf Calculation
71432 Benzene 0.13 93.47 4.6735 Engineering
lb/mmscf lb/mmscf Calculation
108883 Toluene 0.06 39.33 1.9665 Engineering
lb/mmscf lb/mmscf Calculation
100414 Ethylbenzene 0.01 7.73 0.3865 Engineering
lb/mmscf lb/mmscf Calculation
1330207 Xylenes 0.01 8.44 0.422 Engineering
lb/mmscf lb/mmscf Calculation
110543 n-hexane 0.22 154 7.7 Engineering
lb/mmscf lb/mmscf Calculation
Note: The uncontrolled VOC and HAP emissions for this point were calculated using the June 11,
2013 analysis of a gas sample collected from the Sievers LE17-62HN well. The controlled
VOC and HAP emissions factors for point 004 are based on the flare control efficiency of
95%.
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors
listed in the table above with representative component counts, multiplied by the VOC content from the
most recent gas and liquids analyses.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC, HAPS
NANSR Synthetic Minor Source of:
VOC, HAPS
MACT HH Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
AIRS ID: 12319BC3 Page 11 of 12
D of De en f Public n
Air PollutionHealthand ControlEnviro Divisionment
http://ecfr.unoac ce ss.sov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60,Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart 7777-Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:_
https://www.Colorado.qov/oacific/cd phe/oil-and-qas-construction-perm it-self-certification
AIRS ID: 123/9BC3 Page 12 of 12
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: Noble Energy, Inc
Permit Number: 13WE2613
Source Location: SWSW Section 17 T8N R61 W
Point 003: (5) 300 BBL above ground atmospheric crude oil storage
Equipment Description: tanks
Point 003: Plant flare with a minimum combustion efficiency of 95%.
AIRS ID: 123-9BC3-003
Date: July 8th 2014
Review Engineer: Rebecca Vasil
Control Engineer Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
*If tank is a true minor source at a true minor facility, it shall be granted "Final Approval"
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? Yes X No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no"to any of the above, when did you mail an Package received on Aug 13 2013.
Information Request letter to the source? APEN for venting was on general
APEN. Asked for correct APEN.
On what date was this application complete? April 2, 2014
Section 4—Source Description
AIRS Point Equipment Description
003 Five(5) above ground 300 bbl atmospheric crude oil storage tanks. Emissions
from these tanks are controlled by a flare with 95% control efficiency.
004 Separator controlled by a flare stack. Flare has a minimum combustion efficiency of
95%. The flare is enclosed.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
pollutant?
If"yes", for what pollutant? PM10 CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Page 1
Is this source located in the 8-hour ozone non-
attainment region?(Note: If"yes"the provisions of X Yes No
Regulation 7, Sections XII and XVII.C may apply)
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
003 Site-specific using WinSim (Refer to Section 14 for calculations)
004 Site-specific using VOC weight fraction (Refer to Section 14 for calculations)
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/Throughput/Production
003 75,000 BBL per year
004 150 mmscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
003 75,000 BBL per year 2013
004 150 mmscf/yr NA
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
003 75,000 BBL per year
004 150 mmscf/yr
Does this facility use control devices? X Yes No
AIRS Point Process Control Device Description % Reduction Granted
003 01 Flare 95
004 01 Flare 95
Section 6—Emission Summary(tons per year)
Point NO, VOC CO SOx PM10 Single Total
HAP HAP
003 — 13.13 — — — 0.7
(n-hexane) 0.81
PTE: 0.14
004 — 1680 — — — (n-hexane) 0.2
Uncontrolled point 003 0.02 13.13 0.13 — — 0.7 0.81
source emission rate: (n-hexane)
0.14
004 — 1680 — — — (n-hexane) 0.2
003 0.02 0.66 0.13 — -- 0.036 (n- 0.04
Controlled point hexane)
source emission rate: 004 83.9 — — — 0.14 0.2
(n-hexane)
Page 2
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are me Controlled Emission
Pollutant CAS# BIN Emission Rate emissions r
(Ib/yr) reportable Rate(lb/Y)
Point 003
Benzene 71432 A 195 No 9.75
n-Hexane 110543 C 1425 Yes 71.25
Point 004
Benzene 71432 A 14020 Yes 701
Toluene 108883 C 5904 Yes 295
Ethylbenzene 100414 C 1160 Yes 58
Xylenes 1130207 C 1265 Yes 63
n-Hexane 110543 C 23089 Yes 1154
Note: Regulation 3, Part A, Section I1.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory X Yes No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
003 01 VOC CDPHE PS Memo 05-01 Site specific
sampling
004 01 VOC, State only requirement Site-specific gas
HAPS analysis
Section 9—Source Classification
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V X PSD NA NSR X MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If"yes",for which pollutants?Why? VOC, HAPs
For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards (NAAQS)?
If"yes", for which pollutants?Why? NOx emissions are less than 40 TPY.
Page 3
AIRS Point Section 12 R •ulatortr Review
Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or
operator of a source shall allow or cause the emission into the atmosphere of any air
pollutant which is in excess of 20% opacity.This standard is based on 24 consecutive
opacity readings taken at 15-second intervals for six minutes. The approved reference test
method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60,Appendix
0038,004 A(July, 1992)) in all subsections of Section II.A and B of this regulation.
•
Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30%opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
'. r; .i,rise a taasp .moitia..,. ..,:; - _leR. t w g r E r :::Ons!
Section I.A-No person, wherever located, shall cause or allow the emission of odorous
air contaminants from any single source such as to result in detectable odors which are
003&004 measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7)or more volumes of odor free air.
.....:.:. ..:..w .a
leSiellira
Part A-APEN Requirements
003&004 Criteria Pollutants:
(Applicant is required to file an APEN since emissions exceed 1 ton per year VOC)
Part B—Construction Permit Exemptions
003&004 Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold(Rep.,3,Part B,Section 11 D.3.a)
6;flliteta aa=ia`.:4.. r_ 4velaireartaltaattiNgtori
003&004 None
st w � � ®1st -Z X111.�33.� ,..._,. : x:< �, � ��: ,g ga . �-a
003&004 None
i " i t fblt`S_..El k
N-.�p i�,_�:.a � n;.basL.vl It 3L. r ... '- V;KTS a -
003&004 None
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control
Factor CAS# (Y/N) Source (/o)
0.35 VOC No WnSim/EPA 95
Ib/bbl Tanks
0.068 AP-42,
lb/MMBtu NOx No Table 13.5-1 NA
0.37 AP2,
01 Crude oil Storage Tanks Ib/MMBtu CO No Table 1-43.5-1 NA
003
0.0026 Benzene No Winsim/EPA 95
Ib/bbl Tanks
0.019 n-hexane No Winsim/EPA 95
lb/bbl Tanks
SCC 40400301 —Fixed Roof Tank, Oil field storage of crude, breathing losses
22400 Engineering
Ib/MMscf VOC No Calculation 95
0.068 NOx No AP-42, NA
lb/MMBtu Table 13.5-1
0.37 COP-42,
O No NA
Ib/MMBtu Table 13.5-1
003 01 Flare 93.47 Benzene No Engineering 95
lb/MMscf Calculation
39.33 Toluene No Engineering 95
lb/MMscf Calculation
7.73 Engineering
lb/MMscf Eihlybenzene No Calculation 95
8.44 Engineering
lb/MMscf Xylenes No Calculation 95
Page 4
154 n-hexane No Engineering 95
lb/MMscf Calculation
SCC 31000205-Flares
Section 14—Miscellaneous Application Notes
AIRS Point 001 Crude Oil Storage Tanks
Site-specific emission factor using WinSim and EPA Tanks:
VOC = (13.13 TPY*2000)/75000 bbl/yr= 0.35 Ib/bbl
Benzene=(0.0975 TPY*2000)/75000 bbl/yr= 0.0026 lb/bbl
n-hexane=(0.7125TPY*2000) /75000 bbl/yr=0.019 lb/bbl
•
Page 5
AIRS Point 003 Flare
Emissions were calculated using VOC wt fraction.
(scf/hr) '(Ib/Ib-mol)*(%fraction from sales gas analysis)/(379.4 scf/lb-mol) = Ib/hr' (hr/yr)/2000 Ib/T) =
TPY
VOC = (1680 TPY*2000 lb/T)/(150 mmscf/yr=22400 lb/mmscf
NOx and CO (from AP-42, Chapter 13, Table 13.5-1 (NOx=0.068 lb/mmbtu; CO= 0.37 lb/mmbtu)
Emission factors for HAPS are:
Benzene=(14020 Ib/yr)/150 mmscf/yr=93.47 lb/mmscf
Toluene= (5900 Ib/yr)/150 mmscf/yr= 39.33 lb/mmscf
Ethylbenzene= (1160 lb/yr)/150 mmscf/yr= 7.73 lb/mmscf
Xylenes= (1266 Ib/yr)/150 mmscf/yr= 8.44 lb/mmscf
n-hexane= (23100 Ib/yr)/150 mmscf/yr= 154 lb/mmscf
An extended gas analysis was provided in the application dated 06/11/2013. The gas analysis was
perfomed less than a year of submittal.An updated extended gas analysis will not be required because:
-an extended gas analysis was performed within a year of this submittal and included with this package
Page 6
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Air Pollutant Emission Notice (APEN)—and—Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status(Check all that apply) 13 tv E 26 13 Reason for APEN Submittal(Check all that apply) —
AIRS ID#':[23 ' gfl F3 oo3 ❑ APEN update only°
E] New or previously unreported battery ❑ Modification to existing sources
❑ Previously grandfathered battery' ❑ Registration for coverage under general permit no.j G14Q0[≥aen
® Synthetic minor facility cancellation request for individual permits: i ?nh
® Located in the 8-hr Ozone Control Areas ® Application for or Modification of an individual permit
❑ Registered under general permit no.GPO! ❑ Administrative permit amendment'
❑ Permitted under individual permit: ❑ Other:
For individual permit applications,check if you wants: ❑A copy of the preliminary analysis conducted by the Division
❑To review a draft of the permit prior to issuance
Company Names: Noble Energy,Inc OGCC Operator#: 100322
Mailing Address's: 1625 Broadway Suite 2200
tweinerQnobleenergyinc
City: Denver State: CO Zip: 80202 E-mail: ,ern,
Contact Name: Taryn Weiner Phone: (303)2284362 Fax: (303)2284286
Tank Battery Name": BATTERY#415850704 Number of tanks: 5
Location"(QQ Sec.Twp. Range.): SWSW SEC17 T8N R61 W County: Weld Total tank capacity[bbl]: 1500
Calendar year for which"Actual"data applies1s: 2013 Year(s)tank(s)were placed in service°: 2013
Control Description's: FLARE Control Efficiency's: 95%
Condensate Throughput"[bbl/year] Requested": 35;000 7 , c Es for PTE calculation's: .35;000- C.. .. `
S "
Acmal3°: While Controls Operational"
Other equipment at facility'':
Comments:
I
Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit
❑Check if the Division is to calculate emissions. ®Check if site-specific emission factors provided to calculate emissions"3.
Emission Factor ,;. Battery Requested Emissions's Actual Emissions°
Pollutant° [lb/bbl] PTE25 Uncontrolled36 Controlled' Uncontrolled'6 Controlled"
VOC[tons/year] 0.35 i . '3.6713— i's,, 6.-13 03-1 Cr is
NOx[tons/year]
CO[tons/year]
Benzene[lbs/year] 0.0026 is?if 911.00, ,5 91-.00- 'j„f5.4:55-
n-Hexane[lbs/year] 0.019 f 9Z>665.00 i qt>665:00 .f,z;'33.25.
Wells serviced by this tank or tank battery?
An#: 05-123-36639 Name: SIEVERS LEI 7-62HN ®Newly Reported Well
API#: Name: O Newly Reported Well
API#: Name: O Newly Reported Well
API ft: Name: ❑Newly Reported Well
API#: Name O Newly Reported Well il
API#: Name: O Newly Reported Well
API#: Name: O Newly Reported Well
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of II
my knowledge and belief If this is a registration for coverage under general permit GPI,I further certify that this source is and will be operated .r
in full compliance with each condition of general permit GPI.
La II August 9,2013 -
Signature Legally Authorized Person(not a vendor or consultant) Date - -
Taryn Weiner Environmental Engineer
Type or Print Name of Person Signing Above Official Title
Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call:
filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B I (303)692-3150
$250 General Permit fee for each new GP 4300 Cheny Creek Drive South 2963.80
registration to: Denver,CO 802461530
FORM APCD-205
Page 1 of 2 415850704 SIEVERS LE17-62HN APEN
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